The Ninth Circuit has determined that the Fourth Amendment requires a prompt probable cause determination by a neutral and detached magistrate (such as an immigration judge) to justify detention beyond that which may be initially justified by any probable cause determination of removability of a non-citizen being held by a local law enforcement agency pursuant to an ICE detainer.
The full text of Gonzalez v. USICE can be be found here:
https://cdn.ca9.uscourts.gov/datastore/opinions/2020/09/11/20-55175.pdf